Effective September 13, 2016
Afiniti participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Afiniti is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. http://www.privacyshield.gov/list.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Afiniti is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Afiniti may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
US – Swiss Safe Harbor
Afiniti complies with the U.S.–Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Afiniti has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the U.S.–Swiss Safe Harbor program, and to view Afiniti’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
Information Collection and Use
Afiniti does not collect personal information from clients’ customers or callers. Afiniti may collect personal information from representatives of its enterprise clients. For example, approved client employees may be registered for Afiniti Portal access. These client employees may be asked to provide personal information such as their email address. We use this information to administer your account and respond to customer service requests.
If you contact us through our website, we may collect personal information from you that you provide such as your name, email address, or phone number. We use this information to respond to your requests for information about Afiniti.
Service Providers, Sub-Processors, and Onward Transfers
Afiniti may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our clients.
Afiniti is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Afiniti complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If Afiniti is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email or a prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
Upon request Afiniti will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. You may request access, correction, or deletion of your personal information by contacting us at email@example.com. We will respond to these requests within a reasonable timeframe.
Access to Data Controlled by our Clients
Afiniti has no direct relationship with the individuals whose personal data we process. If you are a customer of one of our clients who seeks access, or who seeks to correct, amend, or delete inaccurate data, please contact the client (the data controller) that you interact with directly. Afiniti will respond to the client’s request to amend or delete your data within 30 business days.
We process information for our clients. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.
Afiniti will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients. Afiniti will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you may contact us at firstname.lastname@example.org.
Passive Collection and Tracking Technologies
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
For all other inquiries, please visit our contact page or write to us at:
Privacy @ Afiniti
1700 Pennsylvania Avenue
Washington, DC 20006